| | Memorandum
To: NBB Members and Stakeholders
From: Scott Hughes, Regulatory Director
Date: 9/26/05
Re: Delay Granted for TxLED Implementation & Status of NBB TxLED Equivalent Certification Testing Project
Background
The air quality in approximately 110 east Texas counties is out of compliance with the federal Clean Air Act’s standard for ground-level ozone. In response, the State of Texas revised its compliance plan to do a number of things including a change in the formulation (physical properties) of diesel fuel offered for sale in those non-attainment counties. The goal of these changes is to reduce NOx emissions and other pollutants from diesel-powered vehicles and non-road equipment. The new low emission diesel fuel is commonly referred to as “TxLED”.
Biodiesel is covered by these new “TxLED” regulations. The executive director of the Texas Commission on Environmental Quality (TCEQ) has determined that blending biodiesel into Texas Low Emission Diesel (TxLED) is not acceptable unless the blend has been approved by TCEQ as being equivalent to TxLED in reducing NOx emissions.
These new fuel property requirements were set to take effect for fuel producers beginning October 1, 2005. However, per a decision made last Friday (9/23/05), that date has been delayed for 30 days due to the impact on refining and distribution infrastructure from the recent hurricanes.
The NBB, industry members, and stakeholders have been engaged in this issue for many months and it is one of the industry’s top regulatory priorities.
Status of Industry Sponsored Testing
In order for a biodiesel blend to be approved as having an emissions profile equivalent or better than TxLED, emissions testing must be conducted according to protocols established by TCEQ. The National Biodiesel Board has undertaken a project to test up to three different B20 + additive formulations. The TCEQ has awarded three grants to the NBB to fund these tests in large part with significant additional financial resources being provided by the NBB.
The NBB’s test plan is to conduct the testing on behalf of the industry whereby a B20 blend utilizing biodiesel meeting ASTM D6751 specifications (regardless of feedstock) would be covered if the blend included one of the additive formulations approved by the TCEQ. NBB is partnering with Octel-Starreon to test a B20 with one of their NOx reducing additives; a B20 blend utilizing a generic cetane improver (ethyl hexyl nitrate, aka EHN) which has shown to lower NOx through work done at NREL; and a B20 using a third additive which is yet to be selected.
Locating a reference diesel fuel that could be acceptable to both TCEQ and CARB has been difficult and led to delays in starting the testing. (Note: NBB intends to work with CARB to utilize the results of this testing project for our ongoing CARB B20 testing project). The potential reference fuel is undergoing required fuel analysis that will be reviewed by both TCEQ and CARB in the next week or two. Preliminary data is being sent to them in an effort to speed the approval process. Once we have approval of our reference diesel fuel then we can move to the next phase which is the actual emissions testing. We have collaborated with Southwest Research who will be conducting the testing and are penciled in for a test cell late October/first week of November---given we do not encounter any unexpected hiccups between now and then. There will be a few days of pre-screens and then each additive formulation will take approximately one week to complete its tests. Once we begin testing we will be working diligently to get the information submitted to TCEQ without delay for their review and hopeful approval.
Notes
The counties covered by the TxLED requirement are: Houston area (Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, Waller); Beaumont/Pt. Arthur area (Hardin, Jefferson, Orange); Dallas/Ft. Worth area (Collin, Dallas, Denton, Tarrant, Ellis, Johnson, Kaufman, Parker, Rockwall), Anderson, Angelina, Aransas, Atascosa, Austin, Bastrop, Bee, Bell, Bexar, Bosque, Bowie, Brazos, Burleson, Caldwell, Calhoun, Camp, Cass, Cherokee, Colorado, Comal, Cooke, Coryell, De Witt, Delta, Falls, Fannin, Fayette, Franklin, Freestone, Goliad, Gonzales, Grayson, Gregg, Grimes, Guadalupe, Harrison, Hays, Henderson, Hill, Hood, Hopkins, Houston, Hunt, Jackson, Jasper, Karnes, Lamar, Lavaca, Lee, Leon, Limestone, Live Oak, Madison, Marion, Matagorda, McLennan, Milam, Morris, Nacogdoches, Navarro, Newton, Nueces, Panola, Polk, Rains, Red River, Refugio, Robertson, Rusk, Sabine, San Jacinto, San Patricio, San Augustine, Shelby, Smith, Somervell, Titus, Travis, Trinity, Tyler, Upshur, Van Zandt, Victoria, Walker, Washington, Wharton, Williamson, Wilson, Wise, and Wood counties.
Counties not listed above are not covered by the TxLED requirements and biodiesel and biodiesel blends are not required to be approved by TCEQ as being TxLED equivalent in order to be sold.
Several entities in addition to the NBB have indicated a decision to conduct TxLED equivalency testing for biodiesel blends. Those entities include additive companies, biodiesel producers, and biodiesel marketers. To date, one biodiesel blend formulation has been certified by TCEQ. The certified blend is a B20 utilizing biodiesel made by Biodiesel Industries and utilizing the additive Viscon.
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